From one thing to another. Some risk and safety implications when repurposing operations to support COVID-19 relief

May 05, 2020

As COVID-19 continues to impact all of us around the world, many companies are mobilizing to respond to the sudden, urgent need for vastly greater stocks of diverse medical supplies and equipment. Breweries and distilleries are turning from producing beer and spirits to making hand sanitizers and other alcohol-based disinfectants. Cosmetic companies are pivoting from face creams and perfumes to medical disinfectants and sanitizer gels. Apparel makers are shifting from sewing shirts and dresses to face masks for the public and surgical gowns. Appliance manufacturers are converting their operations to produce ventilators.

AXA XL supports and applauds these efforts.

This article highlights some common safety and risk management issues when companies go from producing one thing to another. It isn’t meant to be a comprehensive list as many safety/risk considerations are unique to individual company operations. Also, classified medical devices that are subject to specific regulations involving testing and certification, like the EU’s Medical Device Regulation, are outside the scope of this article. Nonetheless, we hope this guidance provides companies with useful starting points for identifying and addressing possible safety/risk implications when repurposing their production lines to address the pressing needs posed by the COVID-19 emergency.

Change management

Changing any production process to manufacture different products can create unforeseen hazards. Thus, before venturing down this path, companies should refer to their established change management procedures to ensure that safety, health and environmental risks and hazards are identified and properly controlled.

This includes training employees in managing the changes introduced. The safety of employees is paramount, as whenever something changes in a manufacturing environment, there is often an heightened risk to employees unless they are properly trained. It is essential that employees understand any new processes and/or materials and what needs to be done differently. This is critical not only to avoid mistakes and minimize various operational risks but also for their own safety.

Fire protection

There has been a lot of press coverage about distilleries and craft breweries retooling their operations to produce sanitizers and alcohol-based disinfectants, and apparel manufacturers switching from making clothing to masks, surgical gowns and related products. In these and similar examples, the processes and/or materials used to produce the new end products could worsen the fire risks.

Hand sanitizers, for instance, usually have an alchohol level around 70 percent while in spirits like whiskey and gin, it is typically about 40 percent. Likewise, the tissue or non-woven fabrics used in sanitary masks pose a greater fire risk compared to other fabric types. The fire load of synthetic fabrics, for instance, is double that of natural fibers, and the fire spread with lightweight tissue also can increase dramatically.

Changing any production process to manufacture different products can create unforeseen hazards.

Overhauling a fire protection system takes time and resources, and thus may be unrealistic for companies wanting to act swiftly. Even so, there are basic actions a company can take to address these heightened fire risks including:

Ensuring that all fire protection is in service. Even protection that is not designed for the change will be effective in many situations. A changed operation might erode an a highly protected risk (HPR) safety margin but still provide a reasonable level of protection.

Consider temporary measures such as additional fire watches, portable surveillance such as video imaging detection, and even trained fire crews on standby. Fire watches should be recorded and regularly reviewed to ensure that rounds aren’t missed if some personnel can’t come to work.

If the changes require hot work – using flames or heat for welding, grinding, cutting or brazing – the activities should be carefully managed and supervised within a defined chain-of-command. Incidents involving hot work are the second leading cause of fires in industrial settings, but a strong hot work process can all but eliminate this ignition source.

Ventilation and dust control

Proper ventilation is critical whenever alcoholic products are involved. Similarly, dust control is essential for all manufacturers working with fabrics. In both instances, changes in the interior air quality could be harmful to the workers and equipment as well as lead to elevated fire risks.

The existing systems, of course, should have been designed to ensure a safe, healthy environment considering production levels as well as the alcohol concentrations or types of fabric, respectively. As noted, the alcohol concentrations in disinfectants are substantially greater than in most spirits. And different types of fabric generate more or less dust.

Accordingly, manufacturers first should determine the capacities of their ventilation/dust-collection systems to handle the new operating environment. And if the systems can’t cope with these new demands – and an upgrade isn’t feasible – production may need to be curtailed to ensure a safe working environment.

Also, and equally important, special attention should be given to the maintenance schedules and protocols for cleaning the system(s); in particular, filters may need to be serviced/replaced more frequently.

Storage

Fire protection systems in warehouses/storage facilities are designed to take into account the characteristics and volumes of the materials being stored. If these change, the system may offer much less protection. For example, lightweight paper (<50g @ m2) is a much greater fire risk compared to heavier paper (>100g @ m2). If the facility shifts from storing heavyweight to lightweight paper, the fire risks may exceed the parameters for which the protection system was designed. Again, assuming an upgrade to the fire protection system isn’t feasible, the volumes and storage heights of the materials involved must be reduced to stay within the system’s capabilities.

Alternatively, more flammable materials could be stored in limited piles in staging areas and not in storage racks themselves. Also, areas closer to the water supply usually will have a higher level of sprinkler protection than those at the “remote” end of the system.

Machinery and equipment

When apparel companies start working with new materials, that can produce more wear and tear on the equipment. If so, existing maintenance schedules may need to be revised. Also, more pressure or more power might be needed if the new fabrics are heavier/denser, in which case companies will need to check that the motors and electrical systems can handle these new power requirements.

If a piece of equipment is slated to run past established maintenance intervals, plant operators should review available predictive maintenance records. That will help inform decisions about the tradeoffs between increased production over the short-term and the possibility that production will need to be halted in the medium-term due to a machinery breakdown.

Companies repurposing their operations often need new raw materials or components, or perhaps need vastly greater supplies of existing materials. Both scenarios could mean seeking out new sources. And since firms want to move quickly in response to this emergency, they won’t always be able to carefully review new additions to their supply chains. Moreover, the demand for some raw materials is spiking, promoting stiff competition between companies.

This dynamic has several implications including, for instance, issues related to quality control and credit risk. Thus, when lining up new suppliers, manufacturers should make a reasonable effort to verify a supplier’s quality control procedures while also mitigating potential credit risk, as appropriate.

Other safety considerations

In addition to the issues outlined above:

Signage: As companies change their operations and processes, plant operators should revise safety signage to reflect the usage conditions of new materials.

Houskeeping: Pay close attention to housekeeping. Trash may need to be removed more frequently. Dust, lint and residue may build up more quickly. For processes that cannot be shut down for normal cleaning cycles, establish additional safeguards to compensate for the longer cycles.

Transportation: The rules for transporting products containing alcohol are more stringent that those for transporting, say, orange juice.

How we can help

While the urgency of the COVID-19 emergency demands fast action, I encourage companies thinking about repurposing their operations to pause – briefly – to consider the possible hazards these changes could create, and to implement realistic and prudent measures to lessen the threats.

AXA XL’s Consultants can support your company with this. In fact, the type of issues outlined above reflect discussions we regularly have with clients. That is, when a manufacturing process changes, we help our clients identify the larger and smaller risk and safety issues they need to address.

Finally, let me again thank those companies helping citizens around the world respond to this unprecedented emergency.

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